Appendix—Government
response
Introduction
1. Government provided written evidence
to the Environmental Audit Committee's inquiry into Plastic Bags
and was an expert witness at the EAC's first panel session. Our
written evidence can be found at:
http://data.parliament.uk/writtenevidence/WrittenEvidence.svc/EvidenceHtml/4598
2. The EAC's report on Carrier Bags
agreed that a mandatory charge is a necessary course of action.
However, the Committee recommended some changes to the Government's
policy. This report sets out the Government's response to the
EAC's conclusions and recommendations.
Response to conclusions
1. The Government has multiple aims
for the plastic bag charging policy, including reducing emissions,
waste, and litter, but has not adequately determined their relative
priority. Before proceeding it should have undertaken a structured
appraisal of the evidence on the potential environmental gains
associated with each objective and the extent to which the charge
and type of bag would secure these gains, along with an assessment
of their associated risks and wider implications. It needs to
ensure its analysis is robust and accurate. (Paragraph 15)
2. Given that the proposed English
scheme would have more exemptions than the one in Wales, it is
likely that the reduction in bag use would be lower than the 76%
achieved in Wales. Without additional complexity from exemptions
for small retailers and for biodegradable bags, it might achieve
as large a reduction in bag use and littering. (Paragraph 20)
3. The policy around the exemption
for biodegradable bags appears rushed and taken before reviewing
existing evidence or considering the concerns of all stakeholders.
(Paragraph 54)
4. It appears to us that Defra is
trying to use innovation to justify a rushed and flawed policy
proposal to allow an exemption for biodegradable bags. (Paragraph
59)
5. Defra's proposed exemption for
biodegradable bags is risky and unnecessary. The decision to exempt
biodegradable bags was rushed and taken without considering its
coherence with wider strategies for reducing and managing waste,
and the exemption could also undermine the reduction in bag use
from the 5p charge. It is important that the Government gets the
proposals for the carrier bag charge right, as it is one of the
simplest and most effective ways of reducing resource use and
helping people act in a way that has wider environmental benefits.
The Government's waste management strategy needs to be clear,
consistent and easy to understand in order to secure reduced carbon
emission, improved rates of recycling and avoid contamination
of waste disposal streams. Gains in other areas could be far more
important than can be generated by bags alone. (Paragraph 68)
6. The plastic bag charge is part of
the Government's overall waste management strategy. The Waste
Prevention Programme for England sets out the Government's view
on how to reduce the amount of waste produced and presents the
key roles and actions which should be taken in our transition
towards a more resource efficient, circular economy. It also sets
out the actions Government is taking to support this transition
and the plastic bag charge, with the biodegradable bag exemption,
is a key part of that programme.
7. We recognise that there will always
be a need for some form of bag, for example for impulse buys.
We are therefore looking to develop standards for a biodegradable
bag with industry that has fewer environmental impacts across
its life cycle. A life cycle analysis will be used when setting
the standard for a biodegradable plastic bag that is exempt from
the charge in England. The exemption for biodegradable plastic
bags represents a challenge to UK industry to produce a genuinely
biodegradable plastic bag that meets defined criteria and which
can be reliably identified and separated in waste recovery and
treatment operations. We are not aware that such a plastic bag
currently exists. We therefore expect to see a significant reduction
in the distribution of single-use plastics bags once the charge
is introduced, with a significant proportion of the remaining
single-use plastic bag use moving to biodegradable bags once the
standard is finalised and suitable bags reach the market.
8. Government is keenly aware that the
corollary of greater biodegradable plastic usage in this country
will be the need for more sophisticated separation of waste streams.
We therefore launched a Small Business Research Initiative with
the Technology Strategy Board which closed on 11 December to encourage
innovative solutions to developing more biodegradable bags and
to look at separation techniques. We have provided around £85,000
of funding for four short feasibility studies to be completed
by March. These include two studies into alternative bag materials
and two studies into detection and separation methods for different
plastics in waste streams.
9. If any of these prove promising,
we may invest further in 2014-15 to help develop them into prototypes,
which can take a couple of years. These projects will feed into
our understanding of exemptions for biodegradable bags. However,
a decision on exemptions will be based on the technical and environmental
outcomes we seek, rather than specifying a particular material
or technique. We are also undertaking research with the public
to understand their expectations and possible behaviours around
biodegradable bags.
10. The plastic bag charge is a targeted,
proportionate approach to the problem of carrier bag distribution
and littering. It will therefore focus on plastic bags and not
on paper bags. Paper bags make up less than 0.1% of carrier bags
distributed in the UK by the seven major supermarket retailers.
Plastic carrier bags take longer to degrade in the natural environment,
can damage wildlife and are extremely visible when littered in
our towns, parks and the countryside. The 76% reduction in bag
use achieved in Wales refers only to single use plastic carrier
bags given out by the 7 major supermarket retailers in Wales.
11. Government has chosen to exempt
SMEs from the plastic bag charge to reduce the burden on start-up
and growing businesses in England at a time when the Government
is supporting new growth in our economy. The Government has noted
that some SME representative bodies are in favour of being included
in the charge while others are opposed, and must also consider
impacts on consumers. The Government will continue to welcome
any further evidence on the costs and benefits of exempting SMEs.
12. The Impact Assessment will set out
in more detail the evidence including the costs and benefits of
our approach. However, several of the key impacts of the policy
(e.g. reduced disamenity impact of litter; reduced damage to marine
life) are difficult to measure in quantitative or monetary terms.
13. Although there is evidence that
higher charges can achieve greater impact, a charge set at 5p
has been shown to be highly effective in Wales in substantially
reducing use. Evidence from Ireland suggests that increasing the
size of the charge, or having a credible threat to do so, is important
for sustaining changed behaviours. The Government should implement
a 5p charge for all single-use carrier bags, following the example
of the scheme in Wales, but should review the level of the charge
after two years to assess if an increase is necessary. (Paragraph
23)
14. The evidence from Wales shows that
a charge of 5p is enough to significantly reduce the number of
single use plastic bags that people use. In fact, Northern Ireland
has cancelled a planned increase to 10p in April 2014 as the charge
has been successful at achieving good reductions there. We will,
as a matter of course, be keeping the policy under review.
15. Paper bags can have a greater
emissions impact than plastic bags. Exempting paper bags from
the charge, as the Government proposes, would weaken the message
to reuse bags, diminish the impact of the charge and the likely
reduction in the number of bags used and associated environmental
benefits. The Government should therefore include paper bags in
the charge. (Paragraph 27)
16. The charge will focus on plastic
bags as it is a targeted, proportionate approach to the problem
of carrier bag distribution and littering. Paper bags make up
less than 0.1% of carrier bags distributed in the UK by the 7
major supermarket retailers.
17. Plastic carrier bags take longer
than paper bags to degrade in the natural environment and are
a visible sign of littering in our towns, parks and the countryside.
Plastic carrier bags cost taxpayers in England around £10
million every year in clean-up costs from littering on land and
on beaches. Currently, surveys consistently find around 40 discarded
plastic bags per kilometre of beach.
18. We do not have any evidence to suggest
that the retailing sector will transfer in any significant way
to paper bag usage. Paper bags are more expensive to make, store
and transport, which are disincentives to providing them free
to customers. They are also less appropriate than plastic bags
for many purposes. Government has calculated that even if customers
of large retailers increase their paper bag use by 50% there would
still be a negligible environmental impact in terms of carbon
emissions due to the very low current levels of use.
19. With the introduction of a charging
scheme for single-use bags, the Government should be ready to
introduce legislation to ensure that retailers sell 'bags for
life' at an appropriate higher price than the charge for single-use
bags, taking into account their greater emissions impact. The
Government should set a minimum price for bags for life at a level
which incentivises their reuse; perhaps a minimum of 10p for a
thin and 20p for a thick bag for life that could subsequently
be replaced for free if it breaks. The Government should ensure
any additional proceeds of these charges also go to charity with
retailers allowed to recover the cost of such replacements. (Paragraph
36)
20. It is clear from the Welsh usage
figures that the large retailers that sell Bags for Life will
need to take action to ensure that the charge on single-use plastic
bags does not simply cause customers to use Bags for Life as single-use
carrier bags instead. Retailers set the price for Bags for Life,
but we would encourage retailers to donate the additional proceeds
of their charge to good causes. We will, as a matter of course,
monitor how effective the charge has been, whilst noting that
any future plans to impose a charge on Bags for Life would require
primary legislation with associated timescales.
21. The Government's proposed exemption
for small retailers is unnecessary, and risks adding undue complexity
to the scheme, reducing its environmental impact and reduction
in bag use. There is compelling evidence that small retailers
want to be included in the mandatory scheme as a voluntary approach
could be counter-productive. The Government should include small
retailers in the scheme, but exempt those with 10 employees or
fewer from detailed reporting requirements. As in Wales, all shops
should be required to publicise in-store the proceeds and where
the money is raised is spent. (Paragraph 40)
22. Whilst we support the use of
funds for good causes, such as environmental charities, we are
concerned about potential abuse of the scheme. The Government
should set clear rules for transparent reporting and for retailers
to publicise prominently in store where the funds are going. It
should ensure tough sanctions exist to prevent retailers having
conflict of interest about which charities are supported and ideally
shoppers should decide which local charity the funds go to, as
already happens in some stores. If there is evidence of retailers
abusing this approach, the Government should follow the example
of the landfill tax and plastic bag tax in the Republic of Ireland
by centrally collecting and allocating funds for environmental
projects. (Paragraph 43)
23. Government has chosen to exempt
SMEs from the plastic bag charge to reduce the burden on start-up
and growing businesses in England at a time when the Government
is supporting new growth in our economy. The Government has noted
that some SME representative bodies are in favour of being included
in the charge while others are opposed, and must also consider
impacts on consumers. The Government will continue to welcome
any further evidence on the costs and benefits of exempting SMEs.
24. As in Wales, the Government intends
to require retailers to publicise the number of bags sold and
how the proceeds of the charge have been spent. The exact details
of the scheme are currently being drafted and will take into account
responses to the Call for Evidence.
25. Retailers will be expected to give
the proceeds of the charge to good causes and we are looking into
developing a voluntary agreement with retailers to cover this.
26. Under current proposals the Treasury
intends to take VAT from the proceeds from the bag charge (just
under 1p of the 5p), which would otherwise go to charity. The
estimated £19 million raised in VAT should be spent on new
environmental programmes and to cover the costs of monitoring
the effectiveness of the scheme. This would help reinforce the
wider environmental objectives of the charge and maintain public
support. (Paragraph 45)
27. The Government's spending priorities
are not, in general, determined by the way in which the money
is raised. Hypothecating revenues to particular spending programmes
imparts inflexibility in spending decisions and can lead to a
misallocation of resources, with reduced value for money for taxpayers.
Requiring businesses to report specifically on the VAT on plastic
bags would also introduce additional administrative burden for
those firms involved.
28. More research is needed into
how people respond to the charge including the impact on littering
and recycling. The Government should ensure that retailers collect
and submit data on bag reuse, and monitor how the charge affects
wider behaviours to ensure the scheme has as significant an environmental
impact as possible. (Paragraph 49)
29. We agree that research is needed
to see what people think about the charge now and in future to
understand how consumers respond in practice. As well as learning
the lessons from other parts of the UK the Government has research
underway currently with consumers to understand carrier bag usage
and attitudes, including attitudes to the charge. The Government
will require retailers to submit data on single use plastic bag
distribution. Some retailers also collect data on bag reuse and
we can work with retailers to understand the impacts the charge
is having on reuse. Reporting by retailers is not the only way
to measure bag reuse - for example, research from Wales and Scotland
used a carefully designed sample approach to directly observe
detailed in-store behaviour at the checkout to provide richer
data on how consumers responded. We are considering whether this
approach can be replicated in England.
30. We agree that it will be beneficial
if the charge can affect wider behaviours. However, recent evidence
shows that this will be challenging. Nonetheless, we are supporting
efforts by researchers at Cardiff University, who gave evidence
to the inquiry, to investigate this issue further with a specific
focus on the carrier bag charge.
31. The Government should remove
the proposed exemption for biodegradable bags. It presents risks
to recyclers and might cause as much harm to the natural environment
and wildlife as new or recycled bags. (Paragraph 64)
32. We recognise that carrier bags are
a useful item and that there will always be a need for some form
of bag, for example for impulse buys. We are therefore looking
to develop standards with industry, for a biodegradable bag that
has fewer environmental impacts across its life cycle not just
its end of life impacts. The exemption for biodegradable bags
will not be included in the legislation until standards for the
bags have been finalised. This means the exemption will not come
into effect with the legislation for the 5p charge in October
2015. We will continue to work with the industry to develop the
standard.
33. We are well aware of the concerns
regarding contamination of the recycling stream with biodegradable
plastics and are addressing this with feasibility studies considering
innovative solutions to detect and separate out plastics when
mixed in the waste stream. We will carefully assess the impact
on the industry before introducing any exemption for biodegradable
bags.
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